Memorandum submitted by the Soil Association
(Z38)
SUMMARY
(i) The Voluntary Initiative (VI) is ineffective,
and a pesticide tax is required. The introduction of the Single
Farm Payment marks the end of decades of public subsidies to farmers
designed to achieve more and cheaper food production. The implications
for pesticide use and regulation of this major change in public
policy have yet to be considered (paras 1, 3-5).
(ii) The regulatory framework for agricultural
pesticides has been shaped by policies that prioritised maximising
output and reducing the direct costs of production. Neither are
now objectives of Government policy—public support is decoupled
from production, and focussed on environmental objectives. In
addition, the success of organic farming, both at a technical
and commercial level, has demonstrated that dependency on pesticides
in farming is not in fact essential (paras 7-11).
(iii) In a future characterised by shortages
of fresh water, soil erosion and restrictions on CO2 emissions,
sustainable systems like organic farming will be the only means
of delivering a healthy diet for the world's population in the
medium term (para 6, Annex paras 11-13).
(iv) The VI is a product of the old, maximise
production era; it is of questionable relevance today. The new
goals of agricultural policy are, first, to meet the needs of
consumers (who, as the Food Standards Agency have made clear,
do not want pesticide residues in their food). Second, agriculture
should be sustainable; the application of complex chemicals designed
to kill plants or insects is not sustainable. Against a background
of change and uncertainty, the VI does nothing (and does not claim)
to influence the future direction of agriculture, or meet the
new agricultural policy objectives (paras 12,14).
(v) The VI has generated plans, led to inspection
of sprayers, and some spray operators and farmers have attended
training courses and workshops. Claims of actual impact on the
amount of pesticides being applied, or their impact on the environment
in general and farmland wildlife in particular, may be premature.
If the VI has some value, it could easily be made a requirement
of cross-compliance by Defra, thus ensuring what is likely to
be a significantly higher adherence, at no additional expense
to the taxpayer (paras 12,21).
(vi) The VI is suffers from an number of
serious, inherent flaws: it does not address market distortions;
it will never cover all pesticide use and will not to cover some
farmers likely to be causing most damage; these farmers (free-riders)
will benefit most from the VI; it will not (and does not try to)
influence the overall direction of agriculture, nor the toxicity,
nor even necessarily the amount of pesticides used. There is evidence
from farm assurance schemes and other voluntary agricultural schemes
that the VI may not work (paras 16-17, 19-21).
(vii) The VI does nothing to adjust the current
market failure in pesticide regulation and taxation—consumers
of organic food effectively subsidise the price of non-organic
food. The external costs of non-organic farming, including the
external costs of pesticides, are met by all consumers or taxpayers,
or fall on society as a whole (para 15).
(viii) Unlike a tax, the VI is least likely
to influence those who are keenest on cutting corners, and who
are least concerned about the environment. As a non-financial
instrument, the VI inevitably follows changes in agricultural
practice which are driven by economic forces. These forces, influenced
by farmers personal preferences and existing practice, determine
the pattern of cropping, and to some extent the structure and
management of farms. The VI may then have some impact on the use
of pesticides (para 18).
(ix) A pesticides tax has the possibility,
and more likely the probability, of: influencing the direction
that UK farming takes in future; reducing the amount (and if banded,
the toxicity) of pesticides used; and addressing market distortions.
A tax should be introduced without further delay (paras 22-25).
INTRODUCTION
1. We welcome the Select Committee's investigation,
coming as it does at the start of a new era for European agriculture.
The introduction of the "Single Farm Payment" marks
the end of decades of public subsidies to farmers designed to
achieve more and cheaper food production, and the implications
of this significant change in public policy for pesticide use
and regulation have yet to be considered. We believe that this
enquiry provides an excellent opportunity to start this process.
2. This evidence expands on the points made
in our one-page summary. In addition, in an Annex we cover the
role and work of the Soil Association (Annex, paragraphs 1-5),
and our interest in pesticide use in non-organic farming (Annex,
paragraphs 6-8). We also cover two issues frequently raised about
organic farming when pesticides are discussed: is organic farming
a realistic alternative to farming dependent on pesticides (Annex,
paragraphs 9-13); and the role of pesticides in organic farming
(Annex, paragraphs 14-16).
BACKGROUND
3. For many decades the regulatory framework
for agricultural pesticides has been shaped by post-war policy
considerations, which placed a high priority on maximising output
and reducing the direct costs of production. The framework has
also been influenced by prevailing beliefs within a large part
of the agricultural establishment that pesticides had no harmful
effects (either on human health or the environment) and that there
is no practical alternative to their routine use. Against this
background important questions about the environmental impact
and the safety of pesticides have been ignored, because to have
addressed them would have threatened the basic presumption that
pesticide use was an essential element of food production.
4. In the last few years the situation has
begun to change significantly. A substantial amount of evidence
has become available on the part played by pesticide use in the
dramatic declines of farmland wildlife, including some well-known
song bird species. Evidence suggesting that occupational exposure
to pesticides can have serious health consequences has already
begun to build. Many scientists have expressed concern about the
impact of pesticides (and untested cocktails of several pesticides
acting in combination) on human health, in particular on vulnerable
groups like babies, children and the elderly. In addition, the
success of organic farming, both at a technical and commercial
level, has demonstrated that high dependency on pesticides in
food production systems is not in fact essential.
5. The (then Conservative) Government acknowledged
the problems associated with pesticide use in the 1990 White Paper
on the Environment (This Common Inheritance) and set out its commitment
towards pesticide minimisation and the encouragement of less pesticide
intensive means of control. The Government has since re-affirmed
this policy commitment, formulating policy towards the minimisation
of risks associated with pesticide use and adopting a number of
initiatives aimed at further developing this policy and ensuring
its effective implementation. The decoupling of agricultural subsidies
from food production in the recent Common Agricultural Policy
reforms now provides a major new opportunity to reconsider the
way in which pesticides regulation is framed.
THE FUTURE
6. In a world where CO2 emissions have to
be controlled, fertile soils are being lost at an alarming rate,
and fresh water resources are scarce, sustainable systems like
organic farming will be the only means of delivering a healthy
diet for the world's population in the medium to long term. There
are no longer valid public policy grounds for pesticide regulation
to be conducted on the basis that safety and risk must be balanced
by the need to ensure that farming reliant on pesticides remains
competitive.
7. Increasing food production in the UK
(or EU) is no longer a goal of public policy, and state support
for agriculture has just been decoupled from production. In fact,
state support is just beginning to be "re-coupled" to
environmentally benign farming practises (of which organic is
recognised as the best example, receiving £60 per hectare
under the new Defra Entry Level Stewardship scheme, compared to
£30 per hectare for non-organic farming). The "feed
the world" argument has never been credible, and in the world
we are entering, with the need to conserve soil and fresh water,
and severely restrict CO2 emissions, only sustainable farming
systems will be capable of providing food for the future.
8. All acknowledge that agriculture is entering
a period of significant change, with the introduction of the Single
Farm Payment, but there is disagreement about the new direction
or directions that farming will take.
9. Many in the non-organic part of the industry
suggest that farms will continue to get larger and cropping systems
simpler. It is argued that this will be necessary to allow the
growing of commodity crops to remain, or to become, financially
viable, now that growing such crops attracts no additional subsidy.
Such changes would be likely to at least maintain if not increase
the use of pesticides, and certainly to increase the extent to
which spray regimes are applied less discriminately, as farm management
and labour are spread over more farms and larger areas of crops.
In some areas, these developments are already well underway, and
mirror developments in non-organic agriculture in countries like
the United States and Canada.
10. On the other hand the Government, following
the recommendations of the Curry Commission, wants the farming
and food industries to become more responsive to the public and
the market. In the case of pesticides this would suggest very
significant reductions or an end to their use. Against this background
of significant change and uncertainty about future direction,
the VI does nothing to influence the future direction of agriculture.
DO PESTICIDES
HAVE A
ROLE?
11. The assumptions that frame pesticide
regulation should now be reconsidered in the light of new UK agricultural
policy and the recent reform of the Common Agricultural Policy.
Such reassessment would require a detailed consideration of the
impact of pesticides (and the farming systems they make possible)
on farmland wildlife and the environment, in particular in terms
of CO2 emissions, soil conservation, and the use and pollution
of fresh water. In addition, the hitherto largely ignored issues
of the impact of pesticides and pesticide residues on particularly
vulnerable groups, of multiple routes of exposure and exposure
to multiple residues, and to the impact on individuals likely
to suffer more and or higher levels of exposure to pesticides
and pesticide residues, including bystanders, should be given
urgent attention by the Government and the regulators.
12. As the Voluntary Initiative was a product
of the old, maximise production of cheap food era; it is of questionable
relevance today. The new goals of agricultural policy are, first,
to meet the needs of consumers, who, as the Food Standards Agency
have made clear, do not want pesticide residues in their food.
Second, agriculture is required to be "sustainable",
and the application of complex chemicals designed to kill plants
or insects is clearly not a sustainable practice. The Government
should look again at their approach to pesticides, and should
aim to reduce and eliminate their use through economic and regulatory
instruments, and through the promotion of sustainable farming
systems that do not use pesticides, or aim not to use them.
WEAKNESSES INHERENT
IN THE
VOLUNTARY INITIATIVE
13. The Voluntary Initiative (VI) has succeeded
in raising awareness, generating some management plans, getting
some farmers to inspect their sprayers, and in getting a proportion
of spray operators and farmers to attend training courses and
workshops. It may have reduced the amount of active ingredient
being applied, although given the annual fluctuations in spray
use, and variation in run-off, both significantly affected by
weather conditions and other factors, it may be a little early
for those involved to make claims about any actual impact the
VI is having on the amount of pesticides being applied, or their
impact on the environment in general and farmland wildlife in
particular.
14. There are, however, four serious flaws
inherent in the VI: (i) it does not address market distortions;
(ii) it is unlikely to cover all pesticide use; (iii) it will
fail to cover those farmers likely to be causing most damage;
(iii) these farmers will, as free-riders, benefit most from the
VI; (iv) it will not (and does not try to) influence either the
overall direction of agriculture, nor the toxicity or necessarily
even the amount pesticides used.
15. The VI does nothing to adjust the current
market failure in pesticide regulation and taxation, which ensures
that consumers of organic food effectively subsidise the price
of non-organic food. This is because the external costs of non-organic
farming, and in particular the external costs of pesticides, are
met by either all consumers or all taxpayers, or fall on society
as a whole. For example, the cost of removing pesticides from
water falls on all those who pay water bills, even if they eat
organic food, and also pay the cost of avoiding pesticides through
their slightly higher food bills. The work of the Environment
Agency on monitoring and enforcing the use of pesticides is met
by taxpayers. The notional but severe costs of the loss of farmland
wildlife and wild flowers fall on society as a whole. (There is
already a levy on pesticide sales, equivalent to 1.5% of UK sales.
The revenue from this levy supports the work of the Pesticide
Safety Directorate and the residue monitoring carried out by the
Pesticide Residue Committee, but none of the other costs associated
with pesticide use are covered.)
16. A further strong specific weakness with
the VI is that it is by definition most likely to be adopted by
those farmers already following best practice, or those who have
the greatest desire to do so. It is least likely to influence
those who are least concerned about the impact of pesticides,
keenest on cutting corners, and least concerned about any environmental
impact of their activities.
17. This leaves the problem of free riders.
Unless the VI achieves 100% coverage, there will be a proportion
of farmers not incurring the additional costs associated with
compliance to the VI, and as already stated, on the face of it
these are likely to be farmers causing most environmental and
other damage through their use of pesticides. A tax has the enormous
advantage of impacting on all farmers who use agricultural chemicals,
of impacting most on those who use most chemicals, of not requiring
inspection schemes or other complex (and sometimes costly to the
farmer) schemes to try and ensure compliance, and has the essential
element of fairness embodied in the polluter pays principle.
18. As a non-financial instrument, the VI
inevitably follows changes in agricultural practice, which are
themselves driven by economic forces. Once those economic forces,
with some influence from farmers' personal preferences and existing
practice, have determined the pattern of cropping, and to some
extent the structure and management of farms, then the VI may
or may not have some impact on the use of pesticides. A pesticides
tax, on the other hand, at least has the possibility, and more
likely the probability, of influencing the direction that UK farming
takes in future.
WILL A
"VOLUNTARY" APPROACH
TO PESTICIDES
WORK?—EVIDENCE
FROM OTHER
AGRICULTURAL INITIATIVES
19. An approach based on voluntary codes
of practice and training, rests on the assumption that farmers
generally obey existing laws, and will voluntarily undertake to
meet higher standards. There is some evidence to suggest that
the assumption that laws are generally followed by farmers is
wrong. The Little Red Tractor scheme, which mainly requires farmers
to obey existing laws, in other words, requires them to do things
they would be doing already if they were obeying the law, has
been widely criticised (for example in the farming press) as imposing
an unnecessary and unfair burden on farmers. Assured Food Standards,
who run the Little Red Tractor scheme, have said that in 2000,
22% of farmers were not conforming with the legal requirement
to keep medicine records. The introduction of inspection, where
the keeping of these records was checked (as a requirement of
membership of farm assurance schemes) had reduced the extent of
non-compliance with the law, but in 2004 there was still almost
one in 10 farmers who were not obeying the law. If a legal requirement,
coupled with regular annual inspections to ensure compliance,
still fails to get almost one in 10 farmers to obey the law, it
is hard to see how a voluntary scheme will be effective.
20. There is evidence from another, longer-running
"voluntary initiative" that the voluntary approach is
unlikely to work over time. In 1999, the Government began developing
a strategy to reduce the use of antibiotics and other similar
drugs on farms, due to concerns about the spread of antibiotic-resistant
bacteria from farm animals to people. The strategy is heavily
reliant on a voluntary industry initiative, the Responsible Use
of Medicines in Agriculture Alliance (RUMA). In 1999 the combined
total use of antibiotic growth promoters and therapeutic antibiotics
was 437 tonnes. By 2003 this has risen to 462 tonnes. During the
same period the total weight of animals slaughtered for meat production
fell from 5.756 million tonnes to 5.294 million tonnes, making
non-organic farming less efficient in the use of antibiotics now
than it was in 1999.
21. In any event, if it is thought to have
some value, the provisions of the VI could easily be made a requirement
of cross-compliance by Defra, thus ensuring what is likely to
be a significantly higher adherence to the Initiative, at no additional
expense to the taxpayer.
THE CASE
FOR A
PESTICIDES TAX
22. UK farming and food production should
now be changing, to be focussed on consumer demand and sustainability.
Consumers do not want pesticide residues in their food, and the
use of farming based on pesticide use is not truly sustainable.
The fact that non-organic farmers do not have to pay the full
costs of pesticide use (costs falling on all consumers and taxpayers)
distorts the market. That distortion disadvantages farmers who
do not use pesticides and consumers who eat food produced without
the use of pesticides.
23. Scientific evidence for the negative
environmental impact of pesticides, and farming systems made possible
by the use of pesticides, is clear. There is continuing scientific
concern and growing scientific evidence of the harmful effects
of pesticides on operators, farmers, bystanders, and all people
as they pass through vulnerable stages of their lives (before
and for the next few years after birth, and in old age). There
may be some people who are particularly susceptible to the toxic
effects of pesticides. At the very least, as well as their clear,
negative environmental impacts, there are clearly risks to human
health, and unknowns, associated with the use of pesticides.
24. None of these new policy objectives,
nor the long-standing or newer concerns are addressed by the VI.
The VI brings some new disadvantages, including having least impact
on the least concerned or aware farmers (while adding costs to
the more concerned and aware users of pesticides). A pesticide
tax would be fairer to farmers, fairer to all consumers and taxpayers,
and more effective in delivering the Government's objectives for
UK farming. A tax should be introduced without further delay.
January 2005
Annex
THE SOIL
ASSOCIATION AND
ORGANIC FOOD
AND FARMING
1. The Soil Association is the main organisation
of the organic movement in the UK, and also the main Government-approved
certifier for the UK organic sector, certifying 70% of the organic
food sold in the UK. Our responsibility for organic farming and
food is evident throughout the entire food chain, from consumers,
retailers, processors and wholesalers, to producers, researchers
and policy makers. Membership of the Soil Association charity
(over 25,000) includes members from every link in the chain and
we represent them all in working to develop the organic sector.
2. The objectives of organic farming are
the sustainable management of soil and the natural production
of healthy crops with high nutrient levels, to produce healthy
livestock, and healthy food for humans. This is achieved through
good soil management focussing on the maintenance of soil organic
matter levels and soil biological activity.
3. We hope that over time all farming and
food will switch to modern organic methods. This is currently
the only system that could in future allow us to feed ourselves
sustainably, without depleting non-renewable resources like soil,
fresh water and carbon. Certified organic farming accounts for
about 4% of UK farmland. The market for organic food is worth
over £1 billion, and is growing at 10% per annum. UK organic
farmland is supplying about 45% of this and the rest supplied
by imports. The Government's target is for 70% of the organic
market to be sourced from UK farmers by 2010. Local and direct
organic sales (through farm shops, box schemes and farmers' markets,
and to local schools, pubs and restaurants) are growing at 16%
per annum. An increase in the area of organic farming is one of
the Government's "quality of life" indicators. The Defra
action plan for organic farming, adopted in 2002, and updated
in 2004, supports the development of the sector.
4. In the EU, 13% of Austria's farmland
is organic, with market growth running at 11%, and Germany's annual
market for organic food is twice the UK's, at £2.1billion.
The world-wide market for organic food is worth £15 billion;
the US market (the largest in the world) has grown at between
17 and 22% in recent years, compared to just 2 to 3% growth in
non-organic food, and is expected to be worth $32.3 billion by
2009.
5. Defra, English Nature, the Royal Society
for the Protection of Birds and others have published peer-reviewed
papers setting out in detail the sustainability and biodiversity
benefits of organic farming. The Food Standards Agency have said
that consumers wishing to avoid pesticide residues in food or
to buy sustainable food can buy organic, and English Nature wants
to see more organic farming because there is more wildlife on
organic farms. The Government accepts the sustainability, biodiversity
and animal welfare benefits of organic farming, and the Government's
policy on sustainable public procurement includes encouraging
the purchase of organic food for those reasons. There is good
evidence that organic farming conserves rather than depletes soils
(as is the case with some non-organic farming).
THE SOIL
ASSOCIATION AND
THE USE
OF PESTICIDES
IN NON-ORGANIC
FARMING
6. The Soil Association is interested in
pesticide use for two reasons. First, we exist to promote sustainable
agriculture, and we believe pesticide use encourages unsustainable
systems of farming, which damage the environment, deplete wildlife
and pollute the soil, fresh water and the atmosphere. Second,
the way in which the indirect economic costs of pesticide use
are apportioned between the farmers who use them and society as
a whole, affects the cost of producing non-organic food, and thus
the price differential between organic and non-organic food in
the market place. The organic movement thus has a clear economic
interest in the effective regulation of pesticides.
7. The evidence that agricultural systems
that use pesticides damage the environment is now overwhelming,
and we will not rehearse it further here.
8. We have a clear, and we think reasonable
interest in trying to ensure that non-organic food is produced
at a cost which fully reflects the direct and indirect costs of
production. For example, the fact that all consumers, including
people buying mainly or wholly organic food, pay through their
water bills to remove pesticides from drinking water, means that
organic consumers are effectively subsidising consumers of non-organic
food. Organic consumers not only pay more for their own food,
but also through their water bills allow non-organic consumers
to buy their food at a lower cost. The Environment Agency estimates
the cost of cleaning up pesticides to be around £120 million
per annum. The Soil Association therefore favours non-organic
agriculture paying the full indirect costs that the use of artificial
fertilisers, pesticides and intensive livestock production impose
on society.
WHY LISTEN
TO ADVOCATES
OF A
FRINGE ACTIVITY
LIKE ORGANIC
FARMING?
9. A common response to suggestions that
organic farming provides a viable alternative to non-organic is
the suggestion that widespread adoption of organic farming techniques
will lead to a range of dire consequences which make this alternative
both unrealistic and undesirable, despite the clear environmental
benefits. It used to be regularly suggested that widespread adoption
of organic farming would lead to uncontrollable outbreaks of crop
pests and diseases, and ill health and suffering amongst farm
animals. Extensive and long-term experience of modern organic
farming in a number of countries has made it clear that such claims
are absurd.
10. It is also occasionally suggested that
eating organic food poses additional dangers to human health compared
to non-organic, because of the absence of chemical treatments,
for example to control mycotoxins in grain. The Food Standards
Agency has said clearly that there is no evidence to suggest that
organic food is more dangerous or less healthy than non-organic
food. Indeed recent research shows that mycotoxin contamination
of organic food is either less, or of a sort that is less damaging
to human health, than is the case with non-organic food.
11. The final reason given for suggesting
that organic is not a viable alternative is the suggestion that
widespread adoption of modern organic farming will lead to hunger
and starvation, or at least an inability to feed a growing world
population. Serious data is lacking, but such projections tend
to assume that a rapidly growing world population will all need
to be fed to the (unhealthy) standard of a well-off American.
Such a diet involves the majority of agricultural production being
used to produce animal feed for beef, chickens and pigs, to allow
large-scale consumption of meat. These projections also ignore
the current highly artificial balance of agricultural production,
with high levels of subsidy encouraging over-production in North
America and the European Union, and making the production of many
export crops difficult or impossible in developing countries.
It is sometimes suggested that agricultural production in North
America and the EU would fall by 30% if there were a free market
and free trade in agricultural products. Both the US and the EU
have used publicly funded mechanisms to take agricultural land
out of production in recent years.
12. Organic yields are sometimes lower than
non-organic yields. The difference can be significant, around
20-30%, in the EU, where non-organic agriculture uses high levels
of artificial fertiliser. In the USA, where fertiliser use is
lower, a 20-year trial has shown comparable yields for maize (corn)
with organic actually out-yielding non-organic in a drought year,
because of the greater moisture retention in organically farmed
soils. In developing countries, particularly for poorest farmers
where regular access to artificial fertiliser and pesticides is
problematic or even impossible, organic farming has increased
yields significantly compared to the previous non-organic systems,
sometimes by as much as 100%.
13. From this brief overview, it will be
clear that whether organic or non-organic farming has a better
chance of "feeding the world" is certainly not clear
cut. It is probably true that if everyone on the planet were to
try to eat a typical North American diet, organic farming would
not be able to deliver. However, trying to produce meat on such
a scale would cause horrendous environmental problems and spread
serious diet-related disease beyond the current centres of the
"epidemic" in the US and Western Europe. If the whole,
and growing, population of the planet aspire to a healthy and
balanced diet, with less meat and more pulses, rice and pasta,
organic farming probably could deliver. What is clear is that
in a world where CO2 emissions have to be controlled, soil conserved,
and fresh water resources are scarce, only sustainable farming
systems, like organic, will be able to deliver a healthy diet
for the world's population.
ORGANIC FARMING'S
USE OF
PESTICIDES
14. If organic farming is not dismissed
as irrelevant to a serious discussion about the future of farming
and food because it will cause either ill health or famine, it
is, somewhat paradoxically, dismissed as irrelevant because it
also uses pesticides. Organic principles promote a holistic and
sustainable approach to farming where additional pest control
measures are rarely needed. Organic farming systems rely on prevention
rather than cure, and the main forms of pest control are through
cultural and management methods. Any external or synthetic input
that is required to control disease and pests is a symptom of
unsustainability.
15. The Soil Association is committed to
working towards phasing out the use of all of the chemicals currently
allowed under our standards, to sensible and achievable deadlines.
We allow four pesticides to be used in organic farming: copper,
derris, sulphur and soft soap. These are used to control insects
and prevent diseases in crops; no herbicides (weed killers) are
permitted. Almost all organic arable farming in the UK already
has no need of, and no possibility of using, pesticides. Only
small quantities of the four permitted pesticides are used, and
then only as a last resort. For copper and derris, prior approval
of use has to be given by Soil Association Certification Ltd.
This is only granted if use is clearly justified and no alternative
method of pest control is available. These four pesticides do
not leave significant residues in food.
16. The principal use of the main chemicals
used (sulphur and copper) is to protect potatoes and top fruit
from fungal disease. Sulphur accounts for almost all of the pesticide
used in organic farming—around 100 out of the 120 tonnes
of pesticides used on Soil Association certified farms in 2003.
Sulphur is also used in very large quantities as a pesticide and
also as a fertiliser in non-organic farming. If use as a fertiliser
is included, over 120,000 tonnes a year of sulphur is applied
to UK farmland, less than 0.1% by organic farmers. By contrast,
derris (16 applications in 2003, affecting around 202 hectares)
and copper (86 applications affecting 879 hectares) are little
used by organic farmers. The seven tonnes of copper currently
used by organic farmers each year (likely to be around six tonnes
in 2005 due to further restrictions on use) compares to 703 tonnes
in non-organic farming, where copper is used as a pesticide, soil
conditioner, disinfectant and growth promoter. Finally, UK organic
farmers use around 17,000 litres of soft soap (which is photosensitive,
and breaks down quickly in the environment) each year, mainly
on protected crops.
January 2005
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